Zero Way | EPR Suite
India
EPR Complete Guide
FY 2025–26 · All 8 Streams
Complete Guide · India
Extended Producer Responsibility
A complete guide for Indian businesses: what EPR is, who it applies to, how the compliance cycle works, and how ZeroWay's EPR Suite helps you navigate all eight regulated waste streams.
8
Regulated waste streams
62M
Tonnes of waste per year in India
22%
Formally processed: EPR aims to change this
What Is EPR?
§1
Extended Producer Responsibility shifts the financial and operational burden of post-consumer waste management from local governments and taxpayers to the entities that create the waste: manufacturers, importers, and brand owners.
India adopted EPR progressively from the Plastic Waste Management Rules 2016, accelerating sharply through 2022 (e-waste and batteries) and 2024 (non-plastic packaging).
The Core Principle
If you place a product on the Indian market: whether you made it, imported it, or put your brand name on it: you are legally responsible for ensuring a prescribed percentage of the waste it generates is collected and recycled every financial year. Failure to comply attracts penalties payable into the CPCB Environmental Protection Fund.
Producer
Manufacturer, importer, or brand owner whose products generate waste in India.
POM
Total quantity (MT) introduced into the Indian market in a financial year.
Recycling Target
Minimum % of POM that must be recycled: increasing year-on-year.
EPR Credit
1 credit = 1 MT recycled by a CPCB-registered recycler. Stream-specific.
Annual Return
Filed on CPCB portal by 30 June, declaring POM and credits procured.
EPF Penalty
Environmental Protection Fund fee per tonne of unmet obligation.
India's EPR Legal Framework
§2
EPR compliance in India is governed by eight separate sets of rules issued under the Environment Protection Act, 1986: each covering a different waste stream.
| Waste Stream | Governing Rule |
|---|---|
| Plastic Packaging | Plastic Waste Management Rules 2016 (amended 2018, 2021, 2022) |
| Electronic & Electrical Equipment | E-Waste Management Rules 2022 |
| Batteries (all types) | Battery Waste Management Rules 2022 |
| Tyres | HW & Other Wastes Rules 2016 + CPCB Tyre EPR Guidelines |
| Used Oil & Lubricants | Hazardous Waste Management Rules 2016 |
| End-of-Life Vehicles | Vehicle Scrapping Policy 2021 + MoRTH Guidelines |
| Non-Ferrous Metals | Hazardous & Other Wastes Rules (2025 Amendment) |
| Non-Plastic Packaging | EPR (Non-Plastic Packaging) Rules 2024 |
Registration Is Mandatory Before Selling. No producer, importer, or brand owner may lawfully place regulated products on the Indian market without first obtaining an EPR Registration Certificate from CPCB. This applies from the first unit sold.
The Eight Waste Streams
§3
Plastic Packaging
PWM Rules 2016
4 categories: rigid (Cat I), flexible (Cat II), multi-layer MLP (Cat III: strictest), and compostable (Cat IV). Targets increase annually.
Mfr · Importer · Brand Owner40–50%
E-Waste
EWM Rules 2022
India is the world's 3rd largest e-waste generator. Targets based on 3-year rolling average of sales. All collection must flow to CPCB-registered facilities.
Mfr · Importer (Schedule I)60%
Batteries
BWM Rules 2022
All types: portable to EV batteries: under one framework. Credit rates vary significantly by chemistry. EV sector obligations growing fast.
Mfr · Importer (all types)60–70%
Tyres
HWM Rules 2016
Classified as hazardous waste. India generates ~1.5 MT of waste tyres annually. Producers must ensure a % is retreaded, recycled, or co-processed.
Tyre Mfr · Importer30%
Used Oil
HWM Rules 2016
Mineral-based lubricating oils classified as hazardous. Random discharge constitutes a violation. Must be re-refined or co-processed in cement kilns.
Mfr · Importer of lubricants20–30%
End-of-Life Vehicles
Scrapping Policy 2021
OEMs must ensure vehicles are directed to Registered Vehicle Scrapping Facilities (RVSFs). Uses Certificates of Deposit (CoDs) as the credit instrument.
OEMs · Vehicle ImportersCoD Framework
Non-Ferrous Metals
HWM Rules (2025)
Aluminium, copper, and zinc. New stream: rules still being finalised. Aluminium recycling saves 95% energy vs. primary smelting.
Mfr · Importer of Al/Cu/Zn30–40%
Non-Plastic Packaging
NPP Rules 2024
Paper, glass, metal packaging, and sanitary products now carry recycling obligations. Newest stream: portal systems still being established.
Brand Owners · Producers30–50%
How EPR Fulfilment Works
§6
The EPR compliance process follows the same four-step cycle for every waste stream.
1
Register on CPCB Portal
Obtain an EPR Registration Certificate before placing products on market. Each stream has its own separate portal.
2
Calculate POM & Targets
At the start of each FY, calculate MT placed on market in the preceding year. Apply the target % to determine credits needed.
3
Procure EPR Credits
Buy credits from CPCB-registered recyclers, through PROs, or on the EPR credit marketplace. Credits are stream- and FY-specific.
4
File Annual Return
Submit Annual Return on each CPCB portal by 30 June. Upload POM declaration, EPR credit certificates, and carry-forward data.
Annual Compliance Calendar
1 AprilNew FY begins. Registration renewal required.
April – MayCalculate POM for previous FY. Begin procuring credits.
May – JuneFinalise credit transfers. Upload documentation.
30 JuneAnnual Return filing deadline across all streams.
July onwardsCPCB review period. New year targets take effect.
Biggest Compliance Challenges
§7
Multi-Layered Plastic (MLP)
Lowest recycling infrastructure and strictest targets. Recyclers with genuine MLP capacity are scarce and credit rates are high. CPCB is progressively restricting MLP use.
Multi-Stream Complexity
Each stream has a separate portal, different registration documents, different credit types, and different deadlines. Without a unified tracker, compliance gaps are almost inevitable.
Finding Verified Recyclers
EPR credits from unregistered recyclers are invalid. The CPCB database is not always current and recycler capacity information is difficult to verify independently.
Evolving Targets & Rules
Targets that were 30% two years ago may be 50% today. New streams are added. Businesses must actively monitor CPCB circulars to stay compliant.
Cost of EPR Credits
Credit market prices vary significantly by stream, geography, and season. Producers who wait until May or June pay peak prices. Early procurement and PRO partnerships mitigate this.
EPR and India's Sustainable Development Goals
§8
| Goal | Title | EPR Connection |
|---|---|---|
| SDG 3 | Good Health & Well-being | Formal recycling displaces hazardous informal processing that directly harms waste workers. |
| SDG 8 | Decent Work & Growth | EPR formalises the recycling economy, creating regulated employment for waste pickers and recycler workers. |
| SDG 12 | Responsible Consumption | Producers under EPR have a financial incentive to design products for recyclability (SDG 12.5). |
| SDG 13 | Climate Action | Aluminium recycled under Non-Ferrous EPR uses 95% less energy than primary smelting. |
| SDG 14 | Life Below Water | Plastic EPR targets reduce plastic that would otherwise leach from landfills into rivers and oceans. |
| SDG 15 | Life on Land | Hazardous waste EPR prevents soil contamination from informal dumping and processing. |
Disclaimer: This guide is for informational purposes only and does not constitute legal or regulatory advice. EPR rules and targets are subject to amendment by MoEF&CC and CPCB. Always verify your obligations against the latest CPCB notifications and Official Gazette of India. For specific compliance decisions, consult a qualified legal or compliance professional.